Digital Asset Compliance
Firms that hold, transfer, or broker digital assets face an expanding patchwork of AML, licensing, and reporting obligations; GlobalB Law builds the compliance framework that keeps them operational across Türkiye, the EU, and the US.
Digital asset compliance has shifted from a niche concern to a core regulatory obligation. In Türkiye, crypto service providers have been subject to mandatory registration with MASAK (the Financial Crimes Investigation Board) and BDDK since 2021, with further regulations under the Capital Markets Law imposing licensing and asset custody requirements on crypto exchanges and brokers. In the EU, MiCA has created a comprehensive licensing regime for crypto-asset service providers (CASPs), including custody, exchange, transfer, and portfolio management services. In the US, state money transmitter licences, FinCEN registration, and in some cases SEC and CFTC oversight layer on top of each other depending on the asset class and service type.
GlobalB Law helps digital asset businesses navigate this multi-layered regulatory environment. We assess which activities trigger which obligations in each relevant jurisdiction, design the legal and operational structure of the business to optimise the licensing footprint, draft and submit licence applications, and build the AML/KYC compliance programmes, policies, procedures, customer due diligence workflows, transaction monitoring, and suspicious activity reporting, that regulators expect to see in place before authorisation is granted.
For businesses already operating and facing a compliance gap, we conduct a regulatory health check, prioritise remediation steps, and manage regulator engagement, including responses to information requests and regulatory investigations. Our cross-border team handles Türkiye, the EU, and the US in a single coordinated programme.
What we do
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Which digital asset activities require a licence in Türkiye?
Under Türkiye's Capital Markets Law amendments and related regulations, crypto asset service providers, including exchanges, custodians, and platforms offering buying, selling, or transfer services, must obtain a licence from the Capital Markets Board (SPK). Operating without a licence is a criminal offence. Registration with MASAK for AML purposes is a separate parallel obligation.
What is MiCA and does it apply to our business?
MiCA is the EU Markets in Crypto-Assets Regulation, fully applicable from December 2024. It establishes a single licensing regime for crypto-asset service providers operating in the EU, covering exchange, transfer, custody, issuance, and portfolio management services for crypto-assets that are not already regulated as financial instruments. Any business with EU customers providing these services needs either a MiCA licence or a valid exemption.
We are a Türkiye-based exchange wanting to expand to the EU, what do we need?
You will need a MiCA CASP authorisation from a competent authority in an EU member state. This involves establishing or designating an EU-registered legal entity, submitting a comprehensive application covering governance, AML, IT security, and capital requirements, and obtaining approval, typically a process of six to twelve months. We manage the full application process and advise on the optimal EU jurisdiction for authorisation.
What AML obligations apply to digital asset businesses?
Digital asset service providers are treated as obliged entities under AML/CFT rules in both the EU (6AMLD / AMLA framework) and Türkiye (MASAK regulations). Obligations include customer identification and verification (KYC), beneficial ownership identification, ongoing transaction monitoring, risk-based enhanced due diligence for high-risk customers, suspicious transaction reporting, and record retention. The Travel Rule, requiring originator and beneficiary information to accompany crypto transfers above threshold, applies in the EU and is being implemented in Türkiye.
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